AUDIT REPORT: SAFETY AND SOUNDNESS: OCC’s Supervision of National Bank’s Foreclosure Practices

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AUDIT REPORT: SAFETY AND SOUNDNESS: OCC’s Supervision of National Bank’s Foreclosure Practices

AUDIT REPORT: SAFETY AND SOUNDNESS: OCC’s Supervision of National Bank’s Foreclosure Practices

Office of
Inspector General
DEPARTMENT OF THE TREASURY

May 31, 2012
Thomas J. Curry
Comptroller of the Currency

This report presents the results of our audit of the Office of the Comptroller of the Currency’s (OCC) supervision of foreclosure practices at national banks with large mortgage servicing portfolios during the period 2008 through 2010. Our audit objectives were to determine (1) the sufficiency of existing procedures for supervising loan documentation and foreclosure practices at national banks which own or service mortgage loans and (2) the effectiveness of the application of these procedures.
We included this audit in the Office of Inspector General Fiscal Year 2011 Annual Plan in response to reports of “robo-signing” and document manipulation by financial institutions pursuing foreclosure in connection with the wave of mortgage defaults caused by the economic crisis. Also, this is an area of OCC supervision that we had not previously reviewed.

We conducted our field work principally from November 2010 through March 2011. We interviewed OCC management for Large Bank Supervision, as well as examiners in charge and mortgage lead examiners at three large mortgage servicers. We reviewed documentation related to the planning and execution of examination procedures at these banks during the period 2008 through 2010. In addition, we reviewed the report and supporting enforcement actions from the Interagency Review of Foreclosure Policies and Practices that was issued jointly by the Board of Governors of the Federal Reserve System (FRB), OCC, and the former Office of Thrift Supervision (OTS), in April 2011.1,2 Appendix 1 contains a more detailed description of our objectives, scope, and methodology.

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